Data Protection Commitment

"INFORMED PERSONS AND PROTECTED DATA"

The Management / Governing Body of TOMY´S FASHION TRIBE, S.L.U. (hereinafter, the data controller) assumes the highest responsibility and commitment for the establishment, implementation, and maintenance of this Data Protection Policy, ensuring the continuous improvement of the data controller with the aim of achieving excellence in relation to compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, repealing Directive 95/46/EC (General Data Protection Regulation) (OJ L 119/1, 04-05-2016), as well as Spanish personal data protection legislation (Organic Law, specific sectoral legislation, and its implementing regulations).

The Data Protection Policy of TOMY´S FASHION TRIBE, S.L.U. is based on the principle of proactive accountability, according to which the data controller is responsible for compliance with the legal and case-law framework governing said Policy and is able to demonstrate such compliance to the competent supervisory authorities.

In this regard, the data controller shall be governed by the following principles, which must serve all its staff as a guide and reference framework in the processing of personal data:

1. Data protection by design: The data controller shall apply, both at the time of determining the means of processing and at the time of the processing itself, appropriate technical and organisational measures, such as pseudonymisation, designed to effectively implement data protection principles, such as data minimisation, and to integrate the necessary safeguards into the processing.
2. Data protection by default: The data controller shall implement appropriate technical and organisational measures aimed at ensuring that, by default, only personal data which are necessary for each specific purpose of the processing are processed.
3. Data protection throughout the information lifecycle: Measures ensuring the protection of personal data shall apply throughout the entire lifecycle of the information.
4. Lawfulness, fairness and transparency: Personal data shall be processed lawfully, fairly and in a transparent manner in relation to the data subject.
5. Purpose limitation: Personal data shall be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.
6. Data minimisation: Personal data shall be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
7. Accuracy: Personal data shall be accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay.
8. Storage limitation: Personal data shall be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes of the processing of the personal data.
9. Integrity and confidentiality: Personal data shall be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
10. Information and training: One of the key elements in ensuring the protection of personal data is the training and information provided to staff involved in their processing. Throughout the information lifecycle, all personnel with access to the data shall be duly trained and informed about their obligations regarding compliance with data protection regulations.

The Data Protection Policy of TOMY´S FASHION TRIBE, S.L.U. is communicated to all personnel of the data controller and made available to all interested parties.

Consequently, this Data Protection Policy involves all personnel of the data controller, who must be familiar with it and assume it as their own. Each member is responsible for applying it and for verifying the data protection rules applicable to their activity, as well as for identifying and providing opportunities for improvement that they deem appropriate, with the aim of achieving excellence in relation to compliance.

This Policy shall be reviewed by the Management / Governing Body of TOMY´S FASHION TRIBE, S.L.U. as often as deemed necessary, in order to ensure that it is always aligned with the provisions in force regarding the protection of personal data.